2026 MPFS proposed rule a boon for telehealth, G2211 expansion and more

By Brian Murphy

CMS issued the Medicare Physician Fee Schedule (MPFS) proposed rule this month. Links for further reading below…or just ask ChatGPT? On second thought, don’t do that.

There are a lot of proposals in the rule, but one that I wanted to highlight are changes to telehealth.

I’ve always viewed telehealth as an underutilized service. I was shocked when my dad’s cardiologist flatly declined my proposal to use telehealth for a routine followup. Getting an 81-year-old with mobility issues into an office for a verbal 8-minute conversation that takes two hours round trip for patient and son = frustration.

But hopefully these rules will heighten its adoption. In summary:

• The rule proposes a broader definition of “direct supervision” to include real-time audio/video communication for certain services.
• It ends flexibility that allowed teaching physicians to have a virtual presence for services involving residents, requiring a return to in-person supervision in most settings. However, a rural telehealth exception would continue to allow teaching physicians at rural residency training sites to use audio/video technology for supervision in some cases.
• Finally, CMS is also proposing to streamline the process for adding services to the Medicare Telehealth Services List.

Here’s a few other notable items:

1. Conversion Factors:
   • The proposed rule introduces two distinct conversion factors for 2026, one for clinicians who are qualifying participants in advanced Alternative Payment Models (APMs) and another for all other clinicians.
   • This is a continuation of the trend of recognizing APM participation in Medicare payments, with qualifying participants receiving a slightly higher conversion factor ($33.59 vs. $33.42 for non-qualifying, per the AMA).
2. Quality Payment Program (QPP) changes.
   • The proposed rule maintains the performance threshold for MIPS at 75 points through the 2028 performance period.
   • It includes updates to quality measures, including the addition of new measures and the removal of some existing ones.
   • CMS also proposes six new MIPS Value Pathways (MVPs) for 2026, along with modifications to existing MVPs.
3. Other Key Proposals:
   • The proposed rule includes a new mandatory payment model for heart failure and low back pain.
   • CMS is proposing to make significant changes to physician rate setting by incorporating an efficiency adjustment for codes not based on time.
   • Code G2211 is proposed for wider use, allowing providers to bill it as an add-on code with home or residence E/M services. See article below on this new code by my colleague Crystal May.
   • HCPCS code G0136 (Administration of a standardized, evidence-based SDOH risk assessment tool, 5-15 minutes, not more often than every 6 months) is proposed for elimination. CMS says this is because the code’s resource costs are already captured in existing services such as E/M visits, but the new administration also has shown no love for SDOH in general.

The proposed rule is open for public comment until September 12, 2025.

Reference

• CMS, MPFS proposed rule (press release): https://www.cms.gov/newsroom/press-releases/cms-proposes-physician-payment-rule-significantly-cut-spending-waste-enhance-quality-measures-and
• AMA, Physicians will see Medicare payments rise in 2026: https://www.ama-assn.org/practice-management/medicare-medicaid/physicians-will-see-medicare-payments-rise-2026
• Norwood, OM(G2211)! New HCPCS code leaves mid-revenue cycle professionals with lingering uncertainty: https://www.norwood.com/omg2211-new-hcpcs-code-leaves-mid-revenue-cycle-professionals-with-lingering-uncertainty/
• AAFP, Summary of 2026 proposed MPFS outlines payment boost, other potential wins: https://www.aafp.org/news/government-medicine/2026-mpfs-executive-summary.html